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Substantial Improvement
When buildings undergo repair or improvement, it is an opportunity for floodplain management programs to reduce flood damage to existing structures. More than 21,000 communities participate in the National Flood Insurance Program (NFIP) by adopting and enforcing regulations and codes that apply to development in Special Flood Hazard Areas (SFHAs). Rock Island County's floodplain management regulations and codes meet the minimum NFIP requirements that are not only for new structures, but also for existing structures that are not compliant with our regulations.
In order for Rock Island County residents to be able to participate in the NFIP, one of the duties we must perform, is to determine whether proposed work qualifies as a substantial improvement or repair of substantial damage (referred to as an “SI/SD determination”). If work on buildings constitutes SI/SD, then structures must be brought into compliance with our requirements for new construction, including the requirement that lowest floors be elevated two feet above the base flood elevation (BFE). The our ordinance defines SI/SD as follows:
- SUBSTANTIAL DAMAGE. Damage of any origin sustained by a structure whereby the cumulative percentage of damage during a ten-year period ending on the date of the last damage event equals or exceeds 50% of the market value of the structure before the damage occurred regardless of actual repair work performed. The term includes Repetitive Loss Structures.
- SUBSTANTIAL IMPROVEMENT. Any reconstruction, rehabilitation, addition, or improvement of a structure taking place during the life of the structure in which the cumulative percentage of improvements equals or exceeds 50% of the market value of the structure before the improvement or repair is started, or increases the floor area by more than 20%. Substantial Improvement is considered to occur when the first alteration of any wall, ceiling, floor, or other structural part of the building commences, whether or not that alteration affects the external dimensions of the structure. This term includes structures which have incurred repetitive loss or substantial damage, regardless of the actual repair work done.
Procedures for documenting SI/SD.
- Staff will determine the market value or require the applicant to obtain an appraisal of the market value prepared by a qualified independent appraiser of the building before the start of construction of the proposed work. In the case of repair, the market value of the building shall be the market value before the damage occurred and before any repairs are made. (This is only the structure's value, not the land.)
- Staff will compare the cost to perform the improvement, the cost to repair a damaged building to its pre-damaged condition, or the combined costs of improvements and repairs, if applicable, to the market value of the building.
- Staff will determine and document whether the proposed work constitutes substantial improvement or substantial damage.
- Staff will notify the applicant if it is determined that the work constitutes substantial improvement or repair of substantial damage and that compliance with the flood resistant construction requirements of this subchapter.
- A form shall be used to document the actual calculations for projects and may be required to be recorded in the County Recorder office if the improvements exceed 20%.
This only affects those properties that are not compliant with our floodplain regulations. If you are compliant, then this will not affect you. Being compliant with our regulations will result in lower flood insurance costs. We are community has lived through many floods, many of our homes in the floodplain are compliant with our regulations. However, there are still many out there that are not. If you would like an assessment of what it would take to become compliant, feel free to contact one of our floodplain managers and we can give you some recommendations to become compliant. Don't be afraid of inviting us in, we all have the same goals. We all want you to be at less risk during a flood event. We wants your lives less affected after a flood. The more structures that are compliant, the more we can focus on providing resources to those that have been affected during a flood event.
Items that must be included in the costs of improvement are those directly associated with the work being done on a building or manufactured home. The costs of repairs must include all work necessary to restore a structure to its pre-damage condition. Whether determining costs of improvement or costs of repairs, the determination must include costs associated with complying with any other regulation or code requirement that is triggered by the work. Any list of costs that must be included cannot be exhaustive; however, the following list characterizes the types of costs that must be included:
- Materials and labor, including the estimated value of donated or discounted materials and owner or volunteer labor
- Site preparation related to the improvement or repair, such as foundation excavation or filling in basements
- Demolition and construction debris removal
- Labor and other costs associated with demolishing, moving, or altering structure components to accommodate improvements, additions, and making repairs
- Costs associated with complying with other requirements and codes that may be triggered by the work
- Construction management and supervision
- Contractor’s overhead and profit
- Sales taxes on materials
- Structural elements and exterior finishes, including: "Foundations "Monolithic and other types of concrete slabs "Bearing walls, tie beams, trusses "Joists, beams, subflooring, framing, ceilings "Interior non-bearing walls "Exterior finishes "Windows and exterior doors "Roofing, gutters, and downspouts "Hardware "Attached decks and porches
- Interior finish elements, including: "Floor finishes "Bathroom tiling and fixtures "Wall finishes "Built-in cabinets "Interior doors "Interior finish carpentry "Built-in bookcases and furniture "Hardware "Insulation
- Utility and service equipment, including: "Heating, ventilation, and air conditioning (HVAC) equipment "Plumbing fixtures and piping "Electrical wiring, outlets, and switches "Solar panels and equipment "Light fixtures and ceiling fans " "Security and fire, smoke, and CO2 warning systems "Built-in appliances "Central vacuum systems "Water filtration, conditioning, and recirculation systems
*FEMA 213, Answers to Questions About Substantially Improved/Substantially Damaged Buildings. Washington, DC: Federal Emergency Management Agency, 2018. FEMA https://www.fema.gov/sites/default/files/2020-07/fema_p213_08232018.pdf
The value placed on all donated or discounted materials should be equal to the full actual or estimated cost of such materials and must be included in the total cost. Where materials or service equipment are donated or discounted below market values, the costs should be adjusted to amounts equivalent to normal market costs.
When property owners do their own work, or if volunteer labor is used, then the normal market value or “going rate” for labor must be included in cost estimates. The value of labor should be estimated based on applicable minimum hourly wage rates for the skill and type of construction work that will be done. Wage rates can vary geographically.
In both cases, local officials should verify the estimates based on professional judgment and knowledge of local or regional material costs and construction industry labor wage scales.
*FEMA 213, Answers to Questions About Substantially Improved/Substantially Damaged Buildings. Washington, DC: Federal Emergency Management Agency, 2018. FEMA https://www.fema.gov/sites/default/files/2020-07/fema_p213_08232018.pdf